People v. Gonzales and Soliz

In People v. Gonzales and Soliz (2011) 52 Cal.4th 254, the California Supreme Court considered and rejected the identical argument. Gonzales held the trial court's failure to give any accomplice instructions was harmless because the witness's testimony was sufficiently corroborated by other evidence. (Id. at p. 302.) Gonzales rejected the defendant's argument that prior cases had exclusively reviewed the instructional error under Watson. Gonzales clarified that "in the absence of sufficient corroboration we will submit the omission of accomplice instructions to the harmless error analysis for state law error" under Watson. (Id. at p. 304.)